User Agreement

KASHU, INC. END USER & DATA SHARING AGREEMENT


This End User Agreement ("Agreement") is entered into between you ("End User," "you," or "your") and Kashu, Inc., a Wyoming corporation duly organized and existing under the laws of the State of Wyoming, with its principal place of business located at 1603 Capitol Ave Ste 415 #674380, Cheyenne, WY 82001 ("Kashu," "we," "our," or "us"). By checking the acceptance box presented to you prior to your continued use of or access to any part of the Kashu software, website, or associated services, you acknowledge and affirm that you have read, fully understood, and expressly agree to be legally bound by all terms and conditions outlined herein. This Agreement represents a legally enforceable contract between you and Kashu governing your access to and use of the Kashu platform and related services. If you do not agree to these terms in full, you must not proceed further or access any component of the Kashu ecosystem. Your consent by way of checkbox acknowledgment shall have the same legal effect as a manually executed written contract.


1. DEFINITIONS


For the purposes of this Agreement, the following terms shall have the meanings set forth below and shall apply uniformly throughout all other referenced documents, policies, or related schedules:


"We," "Kashu," and "Us" mean Kashu, Inc., including its affiliates, subsidiaries, employees, contractors, officers, and agents.
"You," "Your," or "Customer" refer to the individual, company, or entity accepting this Agreement by means of electronic consent or using any aspect of the Services offered by Kashu.
"Days" refers to calendar days unless expressly stated otherwise. Any reference to time periods within this Agreement shall include weekends and legal holidays unless specified.
"Effective Date" refers to the date on which you affirmatively indicate your acceptance of this Agreement by checking the designated box on any user interface provided by Kashu.
"Service Materials" means any and all documentation, software tools, visual assets, technical guides, training materials, knowledge bases, user manuals, release notes, integration documentation, tutorials, or customer support content provided by Kashu in connection with your use of the Services.
"Transaction" means any action conducted via the Services that results in a financial event, communication, submission, data retrieval, record generation, authorization request, or payment processing instance, whether initiated manually by the user or through API integration.
"Fee Schedule" refers to the then-current pricing, product offerings, transactional rates, subscription tiers, and associated billing terms for Kashu’s Services as may be updated from time to time and incorporated by reference into this Agreement.
"Partner" shall refer to any third-party service provider, data vendor, payment facilitator, software provider, hosting infrastructure company, compliance partner, or regulatory processor with whom Kashu has a contractual relationship for the purpose of delivering or enabling the Services.
"Service" refers to the suite of software products, APIs, mobile applications, dashboards, user portals, payment services, peer-to-peer systems, business logic engines, and related tools provided directly or indirectly through Kashu or its Partners.
"User" includes you and any employees, contractors, agents, or other individuals who are authorized to access or use the Services under your direction or account credentials, whether directly or indirectly.


2. GRANT OF ACCESS AND LICENSE RESTRICTIONS


Subject to the terms and conditions of this Agreement, Kashu hereby grants you a limited, revocable, non-transferable, non-exclusive, and non-sublicensable right to access and use the Services solely for your internal business or authorized consumer purposes. This right is contingent on your strict compliance with all provisions of this Agreement, any applicable Fee Schedule, and all supporting documentation, laws, and policies.
You shall not, and shall not permit any third party to:
Reverse engineer, decompile, disassemble, or otherwise attempt to discover the source code, underlying algorithms, or technical design of the Services;
Modify, adapt, translate, or create derivative works of the Services or Service Materials;
Copy, distribute, publicly display, reproduce, transmit, publish, or exploit any portion of the Services or Output except as expressly authorized in writing;
Resell, sublicense, lease, rent, host, or make the Services available to any third party outside the scope of your organization’s authorized Users;
Circumvent or disable any security or access controls embedded within the Services;
Use the Services for any unlawful purpose, including but not limited to the violation of any data privacy, anti-money laundering (AML), know-your-customer (KYC), or financial services regulations.
You expressly acknowledge that Kashu is not a consumer reporting agency as defined by the Fair Credit Reporting Act ("FCRA"), nor does Kashu furnish consumer reports within the meaning of the FCRA. You agree not to use any portion of the Services, including any Output, to evaluate or make decisions about an individual’s eligibility for credit, insurance, employment, housing, or any other permissible purpose under the FCRA. You further agree that any violation of these restrictions will constitute a material breach of this Agreement and may result in immediate termination of your access to the Services, in addition to potential civil and criminal penalties under applicable laws.
Your rights to use the Services are expressly conditioned on continued compliance with all restrictions herein. Kashu reserves all rights not expressly granted in this Agreement, and no rights shall be implied by course of dealing, usage of trade, or custom.


3. EXPERIAN AND DMF COMPLIANCE


To the extent that the Services incorporate or rely upon data provided by Experian, Inc. or information derived from the Social Security Administration’s Death Master File ("DMF"), you hereby represent and warrant under penalty of perjury that your use of such data will be in strict compliance with all applicable federal and state laws, regulations, and contractual obligations. Specifically, you certify and affirm the following:
You shall only use deceased indicators or other DMF-derived data for legitimate business purposes, including but not limited to fraud prevention, internal data validation, or regulatory compliance, as permitted under 15 C.F.R. § 1110.102(a)(1). You shall not utilize such indicators in any manner that could result in the denial of benefits, access, or services to a consumer without first conducting a thorough, good faith secondary review and investigation to confirm the accuracy of such indicators.
You further certify that you have entered into all required compliance and data access agreements as mandated by Kashu and any upstream data providers, including but not limited to Experian. You acknowledge that Experian data, whether or not DMF-derived, is subject to strict confidentiality, handling, and retention protocols. You shall not transfer, sublicense, resell, republish, or otherwise disseminate any Experian data to any unauthorized party. You shall maintain and enforce appropriate internal controls, data access restrictions, and disposal policies to ensure secure use, storage, and destruction of Experian and DMF data in accordance with industry best practices and legal obligations.
You agree to permit Kashu to audit or request proof of your compliance with these requirements and to provide any certifications or supporting documentation reasonably requested to ensure lawful use and proper stewardship of sensitive data.


4. SECURITY OBLIGATIONS


You agree and covenant to implement, enforce, and continuously maintain a comprehensive, written information security program that includes robust administrative, technical, and physical safeguards consistent with industry standards, including but not limited to the Gramm-Leach-Bliley Act Safeguards Rule (16 C.F.R. § 314.4). Such safeguards must be designed to:
(a) Ensure the confidentiality, integrity, and availability of any sensitive, confidential, or personally identifiable information processed or accessed through the Services;
(b) Protect against any reasonably anticipated threats or hazards to the security, privacy, or integrity of such data, including unauthorized access, misuse, alteration, or destruction; and
(c) Be commensurate with your organization's size, complexity, and the nature of the data processed through the Services.
You shall ensure that all personnel, agents, and third-party contractors accessing the Services are adequately trained in data security and comply with your security program. In the event of any suspected or confirmed unauthorized access, data breach, security incident, or misuse of the Services or Output, you shall immediately notify Kashu in writing at help@kashupay.com within forty-eight (48) hours of discovery, providing full details of the nature, scope, timeline, and remediation steps.
You agree to cooperate with Kashu, its legal counsel, and affected Partners or regulatory agencies in any investigation, audit, or response plan related to such incidents. You also agree to bear the costs of any notifications or mitigation measures required by law as a result of your acts or omissions.


5. PRIVACY COMPLIANCE


You acknowledge and affirm that the use of the Services may involve the collection, transmission, processing, and storage of personally identifiable information ("PII"), nonpublic personal information ("NPI"), and other consumer and business data protected under federal, state, and international privacy laws. As a condition of use, you agree to implement and uphold all required privacy safeguards, consents, and data governance protocols as required under the following frameworks: the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR), and any future data privacy laws that may become applicable.
You are solely responsible for ensuring that all end-users, consumers, clients, or data subjects whose information is processed through the Services have provided legally sufficient and informed consent for such processing. This includes disclosure of how their data will be used, stored, shared, and retained. You must maintain audit-ready records of such consents and make them available to Kashu upon request.
Kashu may aggregate, de-identify, or anonymize your usage data for analytical, product improvement, marketing, or security purposes in accordance with applicable law. You acknowledge and agree that Kashu retains all ownership rights in such aggregated or anonymized data, and you shall have no claim to such data or any derivative works created therefrom.
Failure to comply with your obligations under this section shall constitute a material breach of this Agreement and may result in immediate termination of your access to the Services and potential legal liability.


6. PAYMENT TERMS


All financial obligations under this Agreement are governed by the applicable Kashu Fee Schedule, which is incorporated herein by reference and may be updated from time to time. You agree to pay all fees, costs, and other charges related to your use of the Services in accordance with the terms set forth in the most current Fee Schedule provided by Kashu. Unless otherwise agreed to in writing by both parties, invoices are issued on a monthly basis and are payable in full within thirty (30) days from the date of invoice issuance. All payments must be made in U.S. dollars and shall be transmitted via wire transfer, ACH, or other payment method approved in advance by Kashu.
Any undisputed fees not paid within the required time frame shall accrue interest at a rate of one and one-half percent (1.5%) per month, compounded monthly, or the highest rate permitted by applicable law, whichever is less. Kashu reserves the right, in its sole discretion and without further notice, to suspend or restrict your access to any portion of the Services in the event of non-payment, delinquency, or returned funds. Reinstatement of Services following a suspension will be subject to a reactivation fee and full settlement of all outstanding balances.
In the event Kashu experiences an increase in underlying partner costs, regulatory fees, data vendor pricing, compliance expenses, or infrastructure surcharges, Kashu shall have the right to adjust your pricing accordingly with a minimum of thirty (30) days’ prior written notice. Such pricing adjustments shall be deemed accepted unless you terminate your use of the affected Services before the effective date of the adjustment. If you dispute any amount invoiced, you must notify Kashu in writing within fifteen (15) days of the invoice date, and both parties shall act in good faith to resolve the dispute promptly.
You shall be solely responsible for all taxes, levies, duties, and similar governmental assessments of any nature, including but not limited to sales, use, VAT, GST, or withholding taxes, associated with your purchases under this Agreement, excluding taxes based on Kashu’s income.


7. OWNERSHIP


You acknowledge and agree that Kashu, including its licensors and affiliates, retains all right, title, and interest in and to the Services, including but not limited to all proprietary software, source code, data structures, interface designs, visual elements, documentation, APIs, processes, workflows, performance metrics, trademarks, service marks, trade secrets, algorithms, and business logic related thereto. Nothing in this Agreement shall be construed to grant you any ownership rights, license, or other proprietary interest in any aspect of the Services other than the limited access rights explicitly provided herein.
Any derivative works, improvements, customizations, or integrations that you or any authorized User may suggest, contribute to, or create in connection with your use of the Services shall be deemed the sole and exclusive property of Kashu. You hereby irrevocably assign and transfer to Kashu all rights, title, and interest in and to any suggestions, enhancement requests, feedback, or recommendations that you may provide, including all intellectual property rights associated therewith.
Kashu acknowledges that any raw data or information you input into the platform or provide for the performance of the Services remains your property. However, you hereby grant Kashu a perpetual, royalty-free, worldwide license to use, reproduce, modify, distribute, and display such data in anonymized, de-identified, or aggregated form solely for the purposes of improving the Services, performing analytics, training internal systems, and supporting compliance with regulatory or legal obligations.


8. CONFIDENTIALITY


You acknowledge that during your use of the Services, you may have access to confidential, proprietary, or non-public information belonging to Kashu or its Partners, including but not limited to system designs, pricing models, trade secrets, business plans, data architecture, customer lists, API documentation, internal reports, software configurations, and platform strategies ("Confidential Information"). You agree to maintain the confidentiality of all such information using at least the same degree of care that you use to protect your own confidential information, but in no event less than reasonable care under the circumstances.
You further agree not to disclose any Confidential Information to any third party without the prior express written consent of Kashu, except where disclosure is compelled by law, regulation, or valid subpoena, in which case you shall provide prompt written notice to Kashu and cooperate in obtaining a protective order or other confidential treatment.
You agree not to use Confidential Information for any purpose other than as necessary to exercise your rights or perform your obligations under this Agreement. Upon termination of your access to the Services, or at Kashu’s written request, you shall promptly return or permanently destroy all copies of Confidential Information in your possession or control, and certify in writing your full compliance with this requirement.
This confidentiality obligation shall survive for a period of five (5) years following the termination or expiration of this Agreement, and indefinitely with respect to any trade secrets, source code, or data security measures disclosed by Kashu. Unauthorized use or disclosure of Confidential Information may result in irreparable harm to Kashu for which monetary damages may be inadequate, and Kashu shall be entitled to seek injunctive relief in addition to all other available legal remedies.


9. TERMINATION


Kashu reserves the right, in its sole discretion and without prior notice, to suspend or permanently terminate your access to the Services at any time in the event of: (i) a material breach of any provision of this Agreement; (ii) any act or attempted act of fraud, misuse, data scraping, system interference, or other prohibited activity; (iii) your violation of applicable federal, state, local, or international law; (iv) repeated late or non-payment of fees; or (v) a request or order by law enforcement, a regulatory authority, or a court of competent jurisdiction.
In addition, Kashu may immediately restrict access to specific features, disable user accounts, or restrict system permissions as a temporary or permanent measure, depending on the nature and severity of the breach.
You may terminate this Agreement voluntarily at any time by (a) ceasing all use of the Services and associated materials, and (b) delivering written notice of termination to Kashu via email at help@kashupay.com or to our official mailing address. Termination shall become effective upon Kashu’s receipt and acknowledgment of your written notice.
Upon termination by either party for any reason, you shall immediately discontinue all use of the Services, and destroy or return all materials, confidential information, API credentials, documentation, and Output. Any licenses or access rights granted under this Agreement shall automatically and irrevocably terminate. You shall not retain any data, tokens, service credentials, or derivative works derived from the Services unless otherwise permitted in writing.
Subject to your compliance with applicable terms and requests made within thirty (30) days of termination, Kashu shall provide you with a one-time export of your permitted data in a commercially reasonable format. You acknowledge that Kashu shall have no further obligation to maintain, store, or recover your data thereafter.


10. WARRANTY DISCLAIMER


You expressly understand and agree that your use of the Services is at your sole risk. Except as otherwise explicitly set forth in this Agreement, Kashu, its officers, directors, employees, agents, licensors, and Partners make no representations or warranties of any kind, express or implied, as to the operation, availability, accuracy, or completeness of the Services, Service Materials, or Output.
To the fullest extent permitted by law, Kashu disclaims all warranties, whether statutory, express, or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, title, quiet enjoyment, and non-infringement. Kashu makes no warranty that the Services will meet your requirements, will operate without interruption, will be error-free or secure, or that the Output generated will be accurate, reliable, or suitable for your intended use.
Kashu does not guarantee or warrant that the Services will be free of viruses, malware, system delays, unauthorized access, service interruptions, or data loss. No advice or information, whether oral or written, obtained from Kashu or through the Services shall create any warranty not expressly stated in this Agreement.
Some jurisdictions do not allow the exclusion of implied warranties, so the above exclusion may not apply to you in whole or in part. In such jurisdictions, Kashu's liability is limited to the greatest extent permitted by law.


11. LIMITATION OF LIABILITY


TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL KASHU, ITS AFFILIATES, OFFICERS, EMPLOYEES, AGENTS, LICENSORS, OR SERVICE PROVIDERS BE LIABLE TO YOU OR TO ANY THIRD PARTY FOR ANY INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES OF ANY KIND, INCLUDING BUT NOT LIMITED TO LOST PROFITS, LOST REVENUE, LOST DATA, BUSINESS INTERRUPTION, OR PROCUREMENT OF SUBSTITUTE SERVICES, ARISING OUT OF OR IN CONNECTION WITH THIS AGREEMENT, THE SERVICES, OUTPUT, OR ANY THIRD-PARTY PRODUCTS OR SERVICES, REGARDLESS OF THE FORM OF ACTION, WHETHER BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, STATUTE, OR OTHERWISE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
IN NO EVENT SHALL THE AGGREGATE LIABILITY OF KASHU FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THIS AGREEMENT EXCEED THE TOTAL AMOUNT PAID BY YOU TO KASHU FOR THE SERVICES IN THE SIX (6) MONTH PERIOD IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM. THIS LIMITATION APPLIES NOTWITHSTANDING ANY FAILURE OF ESSENTIAL PURPOSE OF ANY LIMITED REMEDY AND WHETHER OR NOT KASHU HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
THE PARTIES AGREE THAT THE FOREGOING LIMITATIONS REPRESENT A REASONABLE ALLOCATION OF RISK AND ARE AN ESSENTIAL ELEMENT OF THE BARGAIN BETWEEN THE PARTIES.


12. INDEMNIFICATION


You agree to defend, indemnify, and hold harmless Kashu, its officers, directors, employees, affiliates, agents, licensors, and Partners from and against any and all claims, demands, actions, liabilities, damages, losses, judgments, settlements, costs, and expenses (including reasonable attorneys’ fees and legal costs) arising out of or related to any third-party claim, investigation, regulatory inquiry, or proceeding (collectively, “Claims”) resulting from:
(a) Your breach of any term, condition, representation, or warranty under this Agreement;
(b) Any unauthorized access to or use of the Services, APIs, Output, or data, including any breach of security or data incident caused directly or indirectly by you or any individual under your control or acting on your behalf;
(c) Your violation of any applicable laws, rules, regulations, or third-party rights, including but not limited to intellectual property rights, privacy laws, consumer protection statutes, and financial regulations;
(d) Your failure to implement or maintain reasonable data security measures as required under this Agreement or applicable law.
Kashu shall promptly notify you in writing of any Claim for which indemnification is sought and shall provide reasonable cooperation, at your expense, in the defense and settlement of such Claim. You shall have the right to assume and control the defense of such Claim with counsel reasonably acceptable to Kashu. Kashu shall have the right to participate in such defense with its own counsel at its own cost. You may not settle any Claim without Kashu’s prior written consent if such settlement imposes any obligation, restriction, or admission of liability on Kashu. Your indemnification obligations under this section shall survive the termination or expiration of this Agreement.


13. AUDIT RIGHTS


Kashu reserves the right, but not the obligation, to conduct periodic audits of your use of the Services, APIs, and data to ensure compliance with the terms of this Agreement, applicable laws, and the security and privacy standards required by Kashu and its Partners. Such audits may include, but are not limited to, technical reviews, data access logs, usage reports, security policy assessments, and validation of user access permissions.
You agree to fully cooperate with any audit request made by Kashu or its designated third-party auditors, including providing timely access to your relevant records, personnel, data storage environments, system architecture, and infrastructure. You further agree to make reasonable accommodations to support remote or onsite inspection as necessary. If any audit reveals material non-compliance with this Agreement or misuse of the Services, Kashu may charge you for the reasonable cost of conducting such audit, and you shall promptly reimburse such costs. Kashu may also exercise its rights under the termination and indemnification provisions of this Agreement.


14. GOVERNING LAW AND DISPUTE RESOLUTION


This Agreement shall be governed by, and construed in accordance with, the internal laws of the State of Arizona, without regard to its conflict of laws principles or the United Nations Convention on Contracts for the International Sale of Goods. You agree that any dispute, controversy, or claim arising out of or relating to this Agreement, its interpretation, breach, termination, or the use of the Services (whether in contract, tort, equity, or otherwise), shall be resolved exclusively in the state or federal courts located in Phoenix, Arizona.
You hereby irrevocably submit to the personal jurisdiction of such courts and waive any objection based on venue, forum non conveniens, or any similar ground. Each party agrees to bear its own legal fees and costs in connection with the resolution of any such dispute, except where otherwise provided in this Agreement. The prevailing party in any legal action or proceeding brought to enforce this Agreement shall be entitled to recover its reasonable attorneys’ fees and costs incurred in such action.
Nothing in this section shall prevent either party from seeking injunctive or equitable relief in a court of competent jurisdiction to prevent the unauthorized use or disclosure of its intellectual property or Confidential Information.


15. MISCELLANEOUS


This Agreement, along with any applicable Kashu policies, disclosures, notices, schedules, exhibits, and amendments—whether presented in writing, digitally, or referenced by hyperlink—constitutes the complete, exclusive, and binding understanding between you and Kashu, Inc. with respect to your use of the Services. No oral or written statements, representations, marketing materials, promotional language, or prior agreements not expressly incorporated herein shall have any force or effect.
No modification or amendment to this Agreement shall be valid unless made in writing and signed by an authorized representative of Kashu. You may not assign or transfer any of your rights or obligations under this Agreement without the prior written consent of Kashu, which may be withheld in its sole discretion. Any attempt to do so without prior approval shall be null and void. Kashu may assign or transfer its rights and obligations under this Agreement to an affiliate or successor in interest without restriction.
If any provision of this Agreement is held by a court of competent jurisdiction to be invalid, unlawful, or unenforceable for any reason, such provision shall be deemed severed and the remaining provisions shall remain in full force and effect, and shall be interpreted to achieve the original intent of the parties to the maximum extent legally permissible.
All rights not expressly granted herein are reserved by Kashu. No waiver of any term or condition of this Agreement shall be deemed a continuing waiver of such term or any other term, and Kashu’s failure to assert any right or provision under this Agreement shall not constitute a waiver of such right or provision.


16. DATA COLLECTION AND SHARING DISCLOSURE


This Data Collection and Sharing Disclosure ("Disclosure") is provided by Kashu, Inc., a Wyoming corporation, with its principal address located at 1603 Capitol Ave Ste 415 #674380, Cheyenne, WY 82001 ("Kashu," "we," "our," or "us"). This Disclosure governs how we collect, use, disclose, and retain personal, transactional, technical, and third-party data in connection with our Services. By accessing or using our platform, you acknowledge and agree to the terms set forth herein.


A. Scope of Data Collection


Kashu collects and processes various types of data in the course of delivering our Services. These include:


(i) Personally identifiable information such as name, address, date of birth, government-issued identifiers, contact information, and billing details;
(ii) Transactional and financial information including credit card authorization data, payment routing information, transaction history, card limit utilization, and fund movement metadata;
(iii) Technical information such as IP address, browser type, device identifiers, access logs, clickstream behavior, error diagnostics, and session metadata;
(iv) Partner-sourced data, including but not limited to Experian or SSA DMF-derived data used for fraud prevention and identity validation, provided in accordance with applicable authorization and contractual obligations;
(v) Aggregated or anonymized data that is de-identified and used to improve Services, conduct analytics, or benchmark performance without identifying individual users.
You acknowledge that the nature of our Services requires integration with third-party platforms and data providers, and as such, your data may be transmitted, processed, or stored on secure systems operated by authorized vendors and cloud infrastructure providers.


B. Use of Data


Kashu shall use the data collected solely for the following purposes:
(i) To operate and deliver Services, including user verification, transaction execution, customer support, and compliance monitoring;
(ii) To fulfill contractual obligations to you and to our Partners;
(iii) To assess platform performance, conduct internal analytics, and enhance user experience through feature development and fraud mitigation;
(iv) To comply with applicable federal, state, and international laws, including the Gramm-Leach-Bliley Act (GLBA), California Consumer Privacy Act (CCPA), Fair Credit Reporting Act (FCRA) where applicable, and other data protection frameworks;
(v) To protect the rights, security, and integrity of Kashu, its infrastructure, other users, or the public.
Kashu will not use any data, including Partner-provided data, for any purpose other than what is explicitly authorized by contract and applicable law.


C. Data Sharing


Kashu does not sell your personal data. We may disclose certain data to the following parties:
(i) Authorized Partners and vendors, including but not limited to Experian, banks, payment processors, and cloud service providers, solely to the extent necessary to deliver Services, verify identity, flag deceased indicators, or facilitate disbursements and fund access. All such parties are bound by confidentiality, security, and data use obligations consistent with this Agreement.
(ii) Regulatory authorities or law enforcement, where disclosure is required by court order, subpoena, applicable law, or governmental request. Kashu shall, where permitted by law, provide notice to you of such disclosure and shall cooperate in seeking protective orders to maintain confidentiality.
(iii) With your explicit consent, such as for data portability or external API integrations you authorize in the Kashu application.
(iv) Aggregated or anonymized data that does not identify you individually, used for benchmarking, analytics, market research, or industry reporting.
You acknowledge that use of third-party APIs, such as financial aggregators, payment networks, or compliance tools, may result in limited disclosure of relevant data as necessary to process requests or provide functionality.


D. Security Obligations and Controls


Kashu maintains a written information security program that includes administrative, technical, and physical safeguards consistent with 16 C.F.R. § 314.4 and the requirements of the GLBA, SOC 2, ISO 27001, and other industry-recognized frameworks. These measures include, but are not limited to:


(i) Encryption of data at rest and in transit using TLS 1.2 or higher;
(ii) Access controls and audit logging across sensitive systems;
(iii) Regular third-party assessments, including annual SOC 2 Type II audits;
(iv) Ongoing vulnerability scanning and patch management;
(v) Annual training and background screening for personnel with access to sensitive data.
You agree to implement and maintain complementary safeguards to protect any data accessed or exported through the Kashu platform and to promptly notify Kashu of any suspected breach or unauthorized access.
E. Data Retention and Deletion


Kashu retains data only for as long as necessary to fulfill the purposes described herein, to satisfy contractual or legal obligations, to enforce our rights, and to maintain internal records. Upon termination of Services or at your written request, Kashu will provide a secure export of your data (where permitted) and, subject to regulatory retention periods, will delete or de-identify your information in accordance with our internal data destruction protocols.
Requests for data export or deletion should be submitted to help@kashupay.com and must include sufficient verification to validate identity and authorization.


F. Updates


We may revise this Disclosure from time to time to reflect changes in law, technology, or our practices. Updated versions will be published at www.kashupay.com. Your continued use of the Services after any such update constitutes your acceptance of the revised Disclosure.


If you have questions regarding this Agreement or your use of the Services, please contact us:
Email: help@kashupay.com
Address: 1603 Capitol Ave Ste 415 #674380, Cheyenne, WY 82001
Website: www.kashupay.com